Memorandum 36
Submission from the University of Oxford
EXECUTIVE SUMMARY
The University of Oxford submits that the Government's
recently announced ELQ policy and HEFCE's proposals for its implementation
are seriously flawed, and will not only damage lifelong learning
in general, but also run counter to other Government initiatives
in specific areas of continuing professional development. They
ignore the general benefits to the health of civil society of
a widespread provision of lifelong learning opportunities. They
may additionally impact heavily on training for Christian ministry.
SPECIFIC POINTS
1. The University of Oxford is extremely
concerned about the likely impact on it of the ELQ policy. According
to HEFCE's figures, the University will suffer the fourth largest
(£4.1 million) withholding of grant as a result of the policy.
Three-quarters of that sum is in respect of students in the Department
for Continuing Education, which represents a loss of 70% of its
HEFCE funding. This is a catastrophic cut in funding for a department
which was a pioneer of the university extension movement in the
late nineteenth century.
2. Our analysis of HEFCE's calculation of
the withheld grant demonstrates the inherent danger of using historical
data, which were never intended for this purpose, to underpin
the ELQ policy. We believe that HEFCE has made a number of assumptions
in its analysis of the data which overstate the amount to be withheld.
We have raised this separately with the Funding Council, as it
involves various technical details: together they concern almost
£1 million of funding.
3. The Government introduced the ELQ policy
without prior consultation with the higher education sector. The
policy is, inevitably, beset with unintended consequences. In
its consultative document on the implementation of the policy,
HEFCE attempts some amelioration and argues that there are certain
areas of activity which ought either to be exempt from the withdrawal
of public funding, or for which special provision should be made.
The University suggests to the Committee that the areas so designated
by HEFCE are helpful but have not captured the full picture. In
addition to the "excluded" subjects, including those
for which the Secretary of State has requested exemption and those
which have been formally defined as strategically important and
vulnerable subjects (SIVS), there are many others which have an
importance either to the economy or to the welfare of society,
including those in which there are independent Government initiatives,
where provision will now be put at serious risk unless they, too,
are exempt.
4. There are two groups of courses where
Oxford considers that modifications to the exclusion proposals
are needed, viz Health-related subjects, and Theology.
5. Oxford offers Continuing Professional
Development courses at postgraduate level in Evidence-Based Health
Care, Experimental Therapeutics, Cognitive Therapy, Healthcare
for the Homeless, and Paediatric Infectious Diseases. None of
these are included within the exemptions or, perhaps more appropriately,
the current list of SIVS. Many of our students on these postgraduate
courses have a prior equivalent or higher qualification, but are
maintaining and developing their professional relevance and competence
and/ or training in specific and often interdisciplinary subjects
to underpin their career development, while fulfilling Government's
demands for capacity building. Whilst we acknowledge the role
that employer funding can, and should, play in some areas of CPD,
neither individual students nor, where relevant, the NHS, are
likely to be able to afford full cost fees for these vital professional
development programmes.
6. As the SIVS are currently defined, Cognitive
Therapy is a specific example that will be extremely hard hit.
Students are required to be qualified clinicians in order to undertake
our postgraduate courses, which lead towards professional accreditation,
and most are employed by the NHS. It seems particularly ironic
that Cognitive Therapy has not been categorized as a SIVS in the
light of the Government's announcement in October 2007 pledging
support for training of 3600 extra cognitive therapists to meet
the current shortfall. The economic analysis (by Lord Layard),
which underpins this training plan, showed that, as a result of
the effectiveness of cognitive therapy, there would be no real
cost to Government since there would be consequent savings in
sick pay and benefits. Any withdrawal of funding for Cognitive
Therapy training will, therefore, run directly counter to the
Government's ambitions to build capacity in the area of evidence-based
psychological treatment. If the ELQ policy is implemented, it
is highly likely that these cognitive therapy courses will close.
7. Oxford has a long tradition of working
with the various theological training colleges to provide advanced
academic, yet practical, theological courses, namely the B.Th.
and M.Th. These vocational courses involve skills not normally
part of a Theology BA, and the vast majority of students are ordinands
who already hold an undergraduate or postgraduate degree in another
subject. The churches are unlikely to be able meet the significant
increase in sponsoring costs, and salaries in the churches are
not at a level where such students could possibly afford full-cost
fees themselves. If the ELQ policy is implemented, it is highly
likely that these courses will close. We believe this is an entirely
unforeseen and unintended consequence of the policy, and would
ask that the advanced theological training courses are excluded
from the withdrawal of funding.
8. In addition to these unforeseen consequences
for provision in specific subjects, and for up-skilling, there
is also a severe risk of a reduction in the opportunities for
re-skilling. The impact of the ELQ policy is likely to take two
forms—the cessation of provision, as courses become uneconomic,
and the raising of fees to levels that will exclude large parts
of society, to the detriment of the UK. Examples of the latter
would include women (with degrees from the past) seeking to return
to work and needing to re-skill, graduates on low incomes looking
to change career, people facing life changes through accident
or illness who require new skills, and employees in the public/
voluntary sector.
9. A major casualty of the policy is likely
to be our public engagement programme—the lifelong learning
short course provision which benefits individuals but contributes
to the well-being of civil society as a whole. Such provision
is founded on the principle of open access, and if it is not to
be socially exclusive, costs need to be kept low through public
subsidy. The removal of that subsidy will force either the ending
of such provision, which could well impact more on those who are
"non-ELQ", or the destruction of open access and its
replacement with ELQ policing, means-testing or other intrusive
and burdensome bureaucracy. In this context, it is perhaps worth
noting that, speaking at the Open University on 13 December 2007,
the Secretary of State (John Denham) made reference to how best
to promote such "informal education" in the 21st century.
The withdrawal of public subsidy seems a contrary first step of
promotion.
CONCLUSION
The University of Oxford understands the Government's
position that support for those who have not had the opportunity
to benefit from higher education is a greater priority for public
funding than further support for those who have. But amongst the
latter are many seeking to return to the labour market, or to
re-skill for alternative careers, together with those seeking
to up-skill, and we suggest that to put such flexibility in the
UK employment arena at risk is unwise. It would appear that many
of our concerns arise not from the principles underlying the policy,
but from a failure to analyse its consequences. We would ask the
Committee to enquire whether, at the very least, a delay to allow
mature reflection is not necessary.
January 2008
|
